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Bureau Proposes Improvements to Its No-Action Letter Process and a New Product Sandbox

USA - December 21 2018 Innovative companies face stiff challenges when trying to comply with moribund US consumer protection rules that have not kept pace with technological...

Melanie Brody, Joy Tsai, Alex C. Lakatos.


FinCEN Adds Virtual Currency to High-End Real Estate Reporting Regime

USA - November 20 2018 A perfect storm for AML risk can arise from (i) the use of legal entities to conceal ownership, (ii) the limited application of anti-money laundering...

Thomas J. Delaney, Alex C. Lakatos, Matthew Bisanz.


US Supreme Court Refuses to Review Ninth Circuit Lusnak Decision Requiring National Banks to Abide by State Interest-on-Escrow Laws

USA - November 20 2018 Yesterday, the Supreme Court announced that it would not review the Ninth Circuit's decision in Lusnak v. Bank of America, N.A., 883 F.3d 1185 (9th...

Andrew Tauber, Reginald R. Goeke.


Court Finds That Virtual Currency Is a CommodityFor the Time Being

USA - November 5 2018 On September 26, 2018, a US federal court found that virtual currency constitutes a class of items that are commodities under the Commodity Exchange...

Jerome J. Roche, J. Paul Forrester, Matthew Bisanz.


TILA for Business Loans and Purchases of Receivables? Factors, MCAs, Fintechs and Commercial Lenders Subject to New CA TILA-Like Disclosure Rules

USA - October 5 2018 California enacts a first-of-its-kind legislation imposing disclosure requirements on commercial purpose loans similar to those that the federal Truth...

Jeffrey P. Taft, Steven M. Kaplan, Jonathan D. Jaffe, Eric T. Mitzenmacher, Evan Sippel-Feldman.